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PHMSA ct-2017-gas-program-evaluation
2017 CT NG Program Evaluation - ct-2017-gas-program-evaluation (Connecticut; Natural Gas State Program Evaluation)
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CT NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for CT Dept of Energy and Env Protection Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 1#
CT NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Connecticut Rating: Agency Status: Date of Visit: 07/17/2018 - 07/19/2018 Agency Representative: Karl Baker, Supervisor of Technical Analysis PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Katie Dykes, Chair Agency: Public Utilities Regulatory Authority Address: Ten Franklin Square City/State/Zip: New Britain, CT 06051 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2017 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 44 44 D Compliance Activities 15 15 E Incident Investigations 5 5 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 6 6 I 60106 Agreement State (If Applicable) 0 0 TOTALS 113 113 State Rating................................................................................................................................................... 100.0 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 2#
CT NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data. No issues. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data on Access database. No issues. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data. No issues. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data. No issues. There were no incidents in 2017. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data on spreadsheet. No issues. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Almost all files are electronic and easily accesssable. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Confirmed to be accurate against SABA information. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Regulations are automatically adopted by State statute. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 3#
CT NG Program Evaluation, 2017, page 4Evaluator Notes: GOALS: Maintain accelerated cast-iron and bare steel replacement across all distribution operators. Achieve 100% score on PHMSA evaluation of our state program. Reduce excavation damages. ACCOMPLISHMENTS: Maintained accelerated cast-iron and bare steel replacement. Received 100% score for 2016 PHMSA program audit. Continued with streamlined civil penalty process for excavation damages. Worked on revising State pipeline safety regulations and statutes. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 4#
CT NG Program Evaluation, 2017, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Administrative Procedures, Sections 7, 10 and 11. Standard Inspections are listed on Page 7. Pre-Inspection Activities - Page 12 Inspection Activities - Page 13 Post-Inspection Activities - Page 13 2 2 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Administrative Procedures, Sections 7, 10 and 11. IMP Inspections are listed on Page 8. Pre-Inspection Activities - Page 12 Inspection Activities - Page 13 Post-Inspection Activities - Page 13 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Administrative Procedures, Sections 7, 10 and 11. OQ Inspections are listed on Page 8. Pre-Inspection Activities - Page 12 Inspection Activities - Page 13 Post-Inspection Activities - Page 13 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Administrative Procedures, Sections 7, 10 and 11. Damage Prevention Inspections are listed on Page 8. Pre-Inspection Activities - Page 12 Inspection Activities - Page 13 Post-Inspection Activities - Page 13 1 1 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 5#
CT NG Program Evaluation, 2017, page 65 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Administrative Procedures, Sections 7, 10 and 11. On-site Operator Training are listed on Page 7. Pre-Inspection Activities - Page 12 Inspection Activities - Page 13 Post-Inspection Activities - Page 13 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Administrative Procedures, Sections 7, 10 and 11. Construction Inspections are listed on Page 7. Pre-Inspection Activities - Page 12 Inspection Activities - Page 13 Post-Inspection Activities - Page 13 1 1 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Listed in Administrative Procedures, Section 10, Page 10. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 6#
CT NG Program Evaluation, 2017, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 492.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.46 = 981.20 Ratio: A / B 492.00 / 981.20 = 0.50 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: .5 ratio of inspection days to inspection person years exceeds the needed .38 ratio. No issues. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Each inspector has completed all required core TQ, OQ, DIMP and Root Cause training within the required timeframes. Daniel Tomasino and Kevin Dowling are scheduled or waitlisted for additional IMP TQ classes. Verified on TQ SABA database. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues. Program Manager has over 24 years of experience in pipeline safety. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No response required ? none provided. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Seminar held with the other New England states on October 19-20, 2016, in Portland, ME. 1 1 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 5 5 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 7#
CT NG Program Evaluation, 2017, page 8Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Confirmed that inspections were performed in accordance with Administrative Procedures Section 10. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: State utilizes Federal forms, usually IA, for specialized inspections (e.g. LNG, DIMP, CRM, PAPEI and OQ). O&M form is Federal form supplemented with state regs. Program Manager controls changes to forms. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich Public Utilities in 2013, 2015 and 2017. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich Public Utilities in 2013, 2015 and 2017. 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 1 1 Evaluator Notes: Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich Public Utilities in 2013, 2015 and 2017. Also reviewed when State responds to active excavation damages. 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich Public Utilities in 2013, 2015 and 2017. This is also accomplished during normal review of One-Call damages that are mandatorily reported to the GPSU. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Review and analysis of Operator Annual Reports performed annually (reviewed PIPEDATA.XLS located in S: \GasPipelineSafetyUnit\GASPIPE\Undergnd Facilities). As part of investigation of incidents/accidents, incident/accident data is reviewed for accuracy and to ensure that operators correctly file appropriate PHMSA incident forms. DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 8#
CT NG Program Evaluation, 2017, page 9Trends, program effectiveness and a check for operator issues is performed by using leak response time data, class 2 leak backlog data, third-party damage data and cast iron/bare steel replacement program data. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: No intrastate transmission lines in Connecticut. CT has not been asked by PHMSA, as part of annual interstate inspection plan, to review this data for interstate operators. At request from Zach Barrett to NAPSR, CT has reviewed interstate operator data on PHMSA DataMart, comparing annual report data to NPMS data. 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Annual field inspections are performed on all intrastate operators that are required to have the program. In addition, an annual review of the Drug and Alcohol Testing MIS Data Collection forms is performed. Verification is made that any positive tests are responded to in accordance with the operator's program. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Both headquarters (protocols 1 through 8) last conducted in 2015 and field (protocol 9) inspections, conducted annually, have been performed on all intrastate operators. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No intrastate transmission lines in Connecticut. GPSU has taken part in IMP inspections of interstate operators as part of interstate annual inspection plan. 2 2 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DIMP audits completed on LDCs, Norwich and propane operators per Administrative Procedures. Comprehensive conducted every 5 years, last conducted in 2017 18 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 108352811 2017 Gas State Program Evaluation 2 2 Connecticut CT Dept of Energy and Env Protection, Page: 9#
CT NG Program Evaluation, 2017, page 10PAPEI audits performed on all LDCs and Norwich Public Utilities in 2012 and 2017. 19 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Communications occur with all operators on a regular basis. CT attends and communicates information at Call Before You Dig Board of Directors meetings and Public Awareness meetings. CT attends and provides training at operator training sessions with local officials including fire departments. CT participates in the Northeast Gas Association CT Advisory Group meetings as well. PURA maintains a website that has access to all docketed matters which include all pipeline safety and One-Call enforcement proceedings. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRC's in CY 2017. 1 NA 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All data on class 1 and 2 leaks are required to be submitted to the GPSU on a monthly basis. This data is reviewed to determine trends including any plastic pipe issues. Also, during O&M audits, this is reviewed under 192.617 and during DIMP audits. 22 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed PDF versions of emails located in S:\GasPipelineSafetyUnit\GASPIPE\PHMSA\MONITOR\CY2017. 23 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: No waivers or special permits issued. 1 NA 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Attended meeting in Columbus in CY 2017 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Program Manager was familiar with the metrics and understood the reasons behind the trends. DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 10#
CT NG Program Evaluation, 2017, page 1126 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Verified accuracy. CT was lead on creating the tool through the GAC. 1 NA 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: Only applicable to transmission lines. No intrastate transmission in CT. 1 NA 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 44 Total possible points for this section: 44 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 11#
CT NG Program Evaluation, 2017, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Procedures to notify an operator (company officer) when a noncompliance is identified - Page 15 Procedures to routinely review progress of compliance actions to prevent delays or breakdowns - Page 15 Procedures regarding closing outstanding probable violations - Page 15 Administrative Procedures Sections 12, 13 and 14. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Reviewed various violations reports and civil penalty dockets. Post-inspection briefing is listed on GPSU Inspection Record form that is filled out for each inspection. 90-day written notification is tracked in the Violation database. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Due process is spelled out in the violation letter or civil penalty docket. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Program Manager created the current process for imposing civil penalties. Significant civil penalties were issued in CY 2017 (assessed = $370,200, collected = $492,600). DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 12#
CT NG Program Evaluation, 2017, page 136 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Significant civil penalties were issued in CY 2017 (assessed = $370,200, collected = $492,600). 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 13#
CT NG Program Evaluation, 2017, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Administrative Procedures Section 21. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Administrative Procedures Section 21.4. GPSU staff is on-call 24 hours per day, 7 days per week. Access database tracks incidents. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No incidents in CY 2017. 1 NA 4 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review 3 NA Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: No incidents in CY 2017. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: No incidents in CY 2017. 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No incidents in CY 2017. 1 NA 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: DUNS: 108352811 2017 Gas State Program Evaluation 1 1 Connecticut CT Dept of Energy and Env Protection, Page: 14#
CT NG Program Evaluation, 2017, page 15No incidents in CY 2017. Incidents/accidents have been presented at NAPSR meetings and pipeline safety seminars. In addition, all incident/accident reports are sent to all applicable operators in the state for their review and response to any applicable recommendations included in the report. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 15#
CT NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich in 2013, 2015 and 2017. State regulation, 16-345-4(c)(3) essentially requires all excavators to day-light crossings. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich in 2013, 2015 and 2017. This is also accomplished during normal review of One-Call damages that are reported to the GPSU. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The GPSU has performed a review of the CGA Best Practices document and determined that all pertinent best practices are included in the state regulations. CT revised their underground damage prevention laws in 2016. State program has adopted the 9 elements. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: GPSU collects and evaluates this data. 2013 ? 3.1 total; 1.6 gas 2014 ? 2.9 total; 1.5 gas 2015 ? 2.9 total; 1.4 gas 2016 ? 2.6 total; 1.4 gas 2017 ? 2.2 total; 1.5 gas 2 2 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 16#
CT NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: (1) Surburban LP (2) Connecticut Natural Gas Name of State Inspector(s) Observed: (1) Kevin Dowling (2) Dan Tomasino Location of Inspection: (1) South Windsor (2) East Hartford Date of Inspection: July 18, 2018 Name of PHMSA Representative: Jim Anderson Evaluator Notes: Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: (1) Operator notified of facilities to be inspected during the year (2) Yes 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: (1) Yes (2) Yes Inspection forms kept on laptop and completed in the field. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: (1) Yes (2) Yes 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: (1) NA (2) Yes 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: DUNS: 108352811 2017 Gas State Program Evaluation 2 2 Connecticut CT Dept of Energy and Env Protection, Page: 17#
CT NG Program Evaluation, 2017, page 18(1) Yes (2) Yes 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: (1) Yes (2) Yes 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: (1) NA (2) Yes - followed up with CNG on markout concerns 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: (1) Yes - 2 PVs - 5 ft ignition concerns and could not read nameplate on tank (2) Yes - did not follow locate procedures 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging Info Only Info Only DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 18#
CT NG Program Evaluation, 2017, page 19z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 19#
CT NG Program Evaluation, 2017, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State uses IA to document inspections. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State followed PHMSA Eastern Region inspection plan. 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State submitted required data to Marta Riendeau, Eastern Region. 1 1 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State submitted required data to Marta Riendeau, Eastern Region. 1 1 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No imminent safety hazards found in CY 2017. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 State submitted required data to Marta Riendeau, Eastern Region within timeframe. 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State submitted required data to Marta Riendeau, Eastern Region. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 20#
CT NG Program Evaluation, 2017, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 108352811 2017 Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 21#
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